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Political Campaign Activities

As a tax-exempt, non-profit institution subject to Section 501(c)(3) of the Internal Revenue Code, Santa Clara University is prohibited from participating in, or intervening in, any political campaign on behalf of, or in opposition to, any candidate for public office (“Political Campaign Activities”). 

These Frequently Asked Questions (FAQs) are to provide guidance to the University community to support compliance with federal law.  For the purpose of these FAQs, the “University” refers to Santa Clara University and to the college, the schools, and any other University division, department or unit.

Faculty and staff may participate in Political Campaign Activities, provided that they do so in their individual capacity and do not use University resources, facilities, or personnel.  University employees who engage in Political Campaign Activities in their individual capacity must clearly indicate that their actions and statements are their own and not those of the University.  They may be identified by their University title or role if they make clear that their affiliation with the University is for identification purposes only.

University resources and facilities cannot be used for or made available to political candidates or political campaigns on a partisan basis. While not intended to be an exhaustive list, the following are examples:

  • The University’s name, seal, letterhead, logos or other trademarks may not be used in any manner that suggests or implies support for or opposition to any candidate for political office.
  • The University’s website, social media accounts, letterhead, email accounts, listservs, offices and other facilities, mail distribution services, telephones, computers, copiers, other information technology resources, mailing lists, office supplies, campus addresses, campus services, and administrative or other personnel support may not be used in any manner that suggests or implies support for or opposition to any candidate for political office.
  • University funds may not be used to purchase promotional material, pay for campaign ads, or contribute in any way to a political campaign. Nor may such funds be used to pay honoraria or to cover transportation, accommodation or meal expenses, or any other costs for candidates for public office or for speakers or presenters at an event on behalf of a candidate for political office.
  • Information in support of or opposition to a particular candidate for public office may not be posted, displayed, or linked to on a University-administered website or web page.
  • University property may not be used for the placement of signage of any kind (including but not limited to flyers, posters, banners, stickers or chalking) in support of or opposition to a candidate for public office. (Individual student rooms in the residence halls are not subject to this restriction.)

 

The University is prohibited from engaging in fundraising on behalf of a political candidate or political party.  An individual faculty or staff member may solicit donations for a political candidate only on their own time, in their personal capacity, away from work, and without the use of University resources, facilities, or personnel.

The University may invite candidates to speak on campus, either individually or in a candidate forum, provided that the opportunity to speak is provided on an equal basis to all legally qualified candidates for that political office.  University Marketing and Communications should be notified in advance of the planned invitation. In sponsoring the appearance, the following rules apply:

  • The event must be open to the entire campus community.
  • The event must be a speech, candidate forum, or debate, preferably with the opportunity for questions and answers from the audience.
  • The event cannot be a campaign rally.
  • Fundraising is prohibited.
  • If the appearance is by an individual candidate, the University must provide an equal opportunity to all other legally qualified candidates for that political office.
  • Any candidate forum must be neutral and shall not directly or indirectly favor a particular candidate.
  • Promotions for the event (e.g. social media, emails, flyers, and websites) must explicitly state that the University does not endorse candidates for political office and that the views expressed during the event are those of the speaker and not the University.  
  • At the beginning of the event, the event moderator or another speaker shall make the following statement: “The views expressed during this event are those of the speaker(s) and not the University. Santa Clara University does not endorse or oppose candidates for public office.”

Recognized student organizations may engage in Political Campaign Activities, including but not limited to inviting political candidates or campaign surrogates of their choosing to speak on campus, provided the organization makes clear it is doing so without the endorsement by the University of the candidate, and provided they do not use University resources in the planning or conduct of the activity. Recognized student organizations will have access to University facilities for candidate speeches and other Political Campaign Activities on the same terms and conditions applicable to other student organizations. University Marketing and Communications should be notified in advance of the planned invitation.

When a registered student organization sponsors an appearance by a candidate for political office or a campaign surrogate, the following rules apply:

  • The event must be open to the entire campus community.
  • The event must be a speech, candidate forum, or debate, preferably with the opportunity for questions and answers from the audience.
  • The event cannot be a campaign rally.
  • Fundraising is prohibited.
  • Promotions for the event (e.g. social media, emails, flyers, and websites) must explicitly state the name of the student organization sponsoring the appearance; that use of University facilities for the event does not constitute an endorsement by the University; and that the University does not endorse or oppose candidates for political office.  
  • Promotions for the event (e.g. social media, emails, flyers, and websites) may not use the logo or any other registered trademark of Santa Clara University.  
  • At the beginning of the event, the event moderator or another speaker shall make the following statement: “This event is sponsored by [name of student organization]. The use of University facilities for this event does not constitute an endorsement by the University. The views expressed during this event are those of the speaker and not the University. The University does not endorse or oppose candidates for public office.”
  • Faculty or other administrative advisors to student organizations must take care to avoid the appearance of institutional endorsement and to observe the principles described in these FAQs.

 

Candidates for public office may appear on campus for non-campaign related activities, such as classroom lectures or educational or informational talks to the University community. Other than classroom lectures at the invitation of the faculty member teaching the class, such appearances must be sponsored by a University department or officially recognized campus organization. University Marketing and Communications should be notified in advance of the planned appearance. When such appearances occur, the following rules apply:

  • The speaker must be chosen to speak for reasons other than their candidacy for public office. 
  • The speaker must speak in a non-candidate capacity. 
  • The atmosphere of the event must be non-partisan.
  • Campaigning at the event is not permitted.
  • The individual’s candidacy and the upcoming election should not be referenced.
  • Invitations to the event may not be determined based on political affiliation preferences. 

Faculty may require students to participate in a political campaign of the student’s choice, but only if the University (including the faculty member) does not influence the student’s choice and does not control the student’s campaign work.

Any request from a political campaign or a third-party organization seeking to use University facilities for a candidate appearance or political event must be directed to the University’s Conference Services. Such requests shall be considered in a non-partisan manner in accordance with the policies and procedures applicable to all other third-party requests to use University facilities. University Marketing and Communications should be notified in advance of the request. If the requested use is approved, the following rules shall apply: 

  • The University will provide an equal opportunity to all other legally qualified candidates for that political office to rent space on the same terms and conditions.
  • The University shall charge the candidate or campaign its usual and customary rates for the space and support services, if any.
  • Fundraising is prohibited.
  • Promotions for the event (e.g. social media, emails, flyers, and websites) may not use the logo or any other registered trademark of Santa Clara University.
  • The University will use reasonable efforts to require the candidate or campaign to explicitly state in all promotions for the event (e.g. social media, emails, flyers, and websites) that use of University facilities for the event does not constitute an endorsement by the University and that the University does not endorse or oppose candidates for political office.  
  • The University will use reasonable efforts to require the candidate or campaign to explicitly state at the beginning of the event that: “This event is sponsored by [name of external group]. The use of University facilities for this event does not constitute an endorsement by the University. The views expressed during this event are those of the speaker and not the University. The University does not endorse or oppose candidates for public office.”

The University encourages its faculty, staff, and students to be active and informed participants in the electoral process. Programs that seek to educate people about the electoral process or encourage individuals or groups to register to vote are permissible provided that they are conducted in a non-partisan manner and are not intended to target voters of a particular political party or help particular candidate.

For more information, please see the American Council on Education’s recent publication on Student Voting and College Political Campaign Activities in 2024 or the Internal Revenue Service website addressing the restriction on political campaign interventions by 501(c)(3) organizations.